Rodriguez and Tulali v. Hon.

Blancaflor

Facts:
Previously pending before Judge Blancaflor was Criminal Case No. 22240 for arson (arson case), entitled People of
the Philippines v. Teksan Ami, in which Tulali was the trial prosecutor. A a day before the scheduled promulgation
of the decision in the arson case, Tulali filed an Ex-Parte Manifestation withdrawing his appearance in the said case
to prevent any suspicion of misdemeanor and collusion. He attached to the said manifestation a copy of the
administrative complaint against Awayan filed (but eventually withdrawn) by his superior, Rodriguez, before the
Office of the Governor of Palawan. Judge Blancaflor rendered his decision acquitting Ami of the crime of arson.
Purportedly on the basis of the administrative complaint filed against Awayan and Rodriguez, Judge Blancaflor
informed the petitioners that he was proceeding against them for direct contempt and violation of their oath of
office on the basis of Tulali’s Ex-Parte Manifestation.

Issue: WON Rodriguez and Tulali violated direct contempt for filing Ex-Parte Manifestation withdrawing his (Tulali)
appearance in the said case to prevent any suspicion of misdemeanor and collusion.

Held:
In this case, the Court cannot sustain Judge Blancaflor’s order penalizing petitioners for direct contempt on the basis
of Tulali’s Ex-Parte Manifestation. Direct contempt is any misbehavior in the presence of or so near a court as to
obstruct or interrupt the proceedings before the same, including disrespect toward the court, offensive personalities
toward others, or refusal to be sworn or to answer as a witness, or to subscribe an affidavit or deposition when
lawfully required to do so.

Based on the foregoing definition, the act of Tulali in filing the Ex-Parte Manifestation cannot be construed as
contumacious within the purview of direct contempt. It must be recalled that the subject manifestation bore Tulali’s
voluntary withdrawal from the arson case to dispel any suspicion of collusion between him and the accused. Its filing
on the day before the promulgation of the decision in the pending criminal case, did not in any way disrupt the
proceedings before the court. Accordingly, he should not be held accountable for his act which was done in good
faith and without malice.

Neither should Rodriguez be liable for direct contempt as he had no knowledge of, or participation in, the
preparation and filing of the subject manifestation. It was signed and filed by Tulali alone in his capacity as the trial
prosecutor in the arson case. The attached complaint against Awayan was filed with the Office of the Palawan
Governor, and not with the RTC.

Apparently, Judge Blancaflor’s conclusion, that the subject manifestation containing derogatory matters was
purposely filed to discredit the administration of justice in court, is unfounded and without basis. There being no
factual or legal basis for the charge of direct contempt, it is clear that Judge Blancaflor gravely abused his discretion
in finding petitioners guilty as charged. Indeed, Judge Blancaflor failed to conform to the standard of honesty and
impartiality required of judges as mandated under Canon 3 of the Code of Judicial Conduct.